Petition for Incorporation for Offender Under Supervision — No. 1:22CR02059 (Dkt. 88, E.D. Wash.)

Summary

In this petition (ECF No. 88, filed 05/20/25) in the Eastern District of Washington, U.S. Probation Officer Linda J. Leavitt asks the court to incorporate a new alleged violation by Karla Leticia Padilla-Reyna into pending supervised release proceedings (Case Number 1:22CR02059-MKD-1). Padilla-Reyna was sentenced on May 16, 2023 for wire fraud to 15 months in prison and 36 months of supervised release, which began April 16, 2024; a summons on two earlier violations issued April 4, 2025, and a revocation hearing is scheduled for June 16, 2025. Violation 3 alleges a failure to disclose an open Bank of America Alaska Airlines Visa credit card ending in 4004 after an April 2, 2025 request for all account statements. The card appears in a Central District of California forensic report on another offender, Marilu Nava, as payment for an EoS Fitness membership.

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Case 1:22-cr-02059-MKD ECF No. 88 filed 05/20/25 PageID.429 Page 1 of 3
PROB 12C Report Date: May 19, 2025
(6/16)
FILED IN THE
United States District Court U.S. DISTRICT COURT
EASTERN DISTRICT OF WASHINGTON

for the May 20, 2025
SEAN F. MCAVOY, CLERK
Eastern District of Washington

Petition for Incorporation for Offender Under Supervision

Name of Offender: Karla Leticia Padilla-Reyna Case Number: 0980 1:22CR02059-MKD-1
Address of Offender: Yakima, Washington 98901
Name of Sentencing Judicial Officer: The Honorable Mary K. Dimke, U.S. District Judge
Date of Original Sentence: May 16, 2023
Original Offense: Wire Fraud, 18 U.S.C. § 1343
Original Sentence: Prison - 15 months Type of Supervision: Supervised Release
TSR - 36 months
Asst. U.S. Attorney: Frieda Zimmerman Date Supervision Commenced: April 16, 2024
Tyler Tornabene
Defense Attorney: Robin Emmans Date Supervision Expires: April 15, 2027

PETITIONING THE COURT

To incorporate the violation contained in this petition in future proceeding with the violations previously reported
to the Court on 04/04/2025.

On April 19, 2024, supervised release conditions were reviewed and signed by Ms. Padilla-Reyna acknowledging
an understanding of her conditions.

On April 4, 2025, a summons was issued relating to two violations as noted in ECF No. 74. On April 23, 2025, Ms.
Padilla-Reyna’s initial appearance on supervised release petition was held. A supervised release revocation hearing
is scheduled for June 16, 2025.

The probation officer believes that the offender has violated the following condition of supervision:

Violation Number Nature of Noncompliance

3 Special Condition #1: You must provide the supervising officer with access to any
requested financial information and authorize the release of any financial information. The
probation office may share financial information with the U.S. Attorney’s Office. You must
disclose all assets and liabilities to the supervising officer. You must not transfer, sell, give
away, or otherwise convey any asset, without the advance approval of the supervising
officer.

Supporting Evidence: Ms. Padilla-Reyna is alleged to be in violation of her conditions of
supervised release by failing to disclose an open/active Bank of America Alaska Airlines
Visa credit card to the probation officer since April 2, 2025.
Case 1:22-cr-02059-MKD ECF No. 88 filed 05/20/25 PageID.430 Page 2 of 3
Prob12C
Re: Padilla-Reyna, Karla Leticia
May 19, 2025
Page 2

On April 2, 2025, this officer emailed Ms. Padilla-Reyna the following: “Can you please
send me all of your bank statements from every account you have, i.e. checking and savings
with just your name or your name and Sergio's name from January 1- through April 1, 2025.
His accounts are your accounts, so I need copies of statements from every account.” The
requested documents were received April 4, 2025.

On May 15, 2025, this officer received a copy of a digital forensic examination report and
two attachments labeled signal communications and exported results conducted in the
Central District of California, on May 5, 2025, regarding active offender, Marilu Nava. Per
the Central District of California, their court granted permission for the documents to be
shared with our district. The report contained information relating to Ms. Padilla-Reyna.

In the digital forensic examination report under other artifacts of interest, it notes, “ The
exam yielded Apple Mail artifacts showing Apple receipts paid by Karla Padill [sic]. The
artifact also shows that Karla Padilla Nava is the account holder for a membership at EoS
Fitness. The member name is Marilu Nava.” Per the examination report, on April 5, 2025,
a new agreement was entered into with EoS Fitness and Marilu Nava as paid by account
holder Karla Padilla-Nava. The credit card used was a Bank of America Alaska Airlines
Visa credit card ending in 4004. It notes the card holder name as Karla Padilla Nava.

On May 16, 2025, this officer emailed Ms. Padilla-Reyna and her attorney the following,
“Good morning. I have reviewed, again, all the documents you sent me when I asked for all
of your financial accounts. What you sent includes the below. Can you confirm the below
are all the accounts you currently have. One of the statements you have sent doesn't have the
bank name, please answer my questions in red:
• HAPO 3923010, says auto loan
• HELOC Premier, who is this through?
• Primary Savings ending in 8867, who is this through, is this HAPO as well?
• Solarity line of credit acct number 168667"

On May 19, 2025, Ms. Padilla-Reyna responded and answered the questions via email
regarding the above-noted request. She stated the following: “I thought I responded Friday
but I sent it to Robin only. I had 4 vaccinations on Thursday (flu, pneumonia, Covid and
shingles) and had a very bad reaction. I didn't want to respond because I was very foggy and
had an immense headache. Those listed below are all the accounts.”

Ms. Padilla-Reyna did not disclosed the Bank of America Alaska Airlines Visa credit card
ending in 4004.

The U.S. Probation Office respectfully recommends the Court incorporate the above-noted allegation with the
pending petition before the Court.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on: 05/19/2025
s/Linda J. Leavitt
Linda J. Leavitt
U.S. Probation Officer
Case 1:22-cr-02059-MKD ECF No. 88 filed 05/20/25 PageID.431 Page 3 of 3

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